ML20195F177
| ML20195F177 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Palo Verde |
| Issue date: | 05/30/1986 |
| From: | Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20151J031 | List: |
| References | |
| FOIA-87-866 NUDOCS 8606100453 | |
| Download: ML20195F177 (28) | |
See also: IR 05000530/1986003
Text
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May 30,1986
MEMORANDUM FOR:
D. F. Kirsch, Director
Division of Reactor Safety and Projects, Region V
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FROM:
J. G. Partlow, Director
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Division of Inspection Programs
Office of Inspection and Enforcement
SUBJECT:
ASSESSMENT OF IMPLEMENTATION OF THE NRC INSPECTION
PROGRAM BY REGION V AT PALO VERDE UNIT 3
The Office of Inspection and Enforcement described to the Commission in
SECY-82-150A the assessment of the implementation of the NRC inspection
program in conjunction with Construction Appraisal Team (CAT) inspections.
Accordingly, we have examined Region V's implementation of the construction
inspection program based on the January-February 1986 CAT inspection at the
Palo Verde Unit 3 site.
The results of the inspection were documented in
Inspection Report 50-530/86-03 dated April 4, 1986.
The enclosure to this
memorandum documents the results of our assessment of the construction
inspection program implementation,
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ORIGittAL SIGa..
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J. G. Partlow, Director
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Division of Inspection Programs
Office of Inspection and Enforcement
Enclosure:
Assessment
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J. Taylor, IE
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R. Spessard
R. Heishman
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REGInNAL CONSTRUCTION INSPECTION
PROGRAM ASSESSMENT - OUTLINE
FOR PALO VERDE UNIT 3
1.
Objective
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II.
Assessment Activities
III. Assessment Findings
A.
Discipline Areas
1.
CAT Findings
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2.
Assessment
3.
Recommendations
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IV.
Review of Construction Inspection Program
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A.
Scope
B.
Assessment
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C.
Recommendations
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V.
SALP Reports
VI.
Regional Assessment of 1985
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VII. Overall Assessment Lonclusions
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REGIONAL CONSTRUCTION INSPECTION PROGRAM
ASSESSMENT - PALO VERDE UNIT 3 (R-V)
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1.
OBJECTIVE
The objective of this assessment is to evaluate Region V's implementation
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of the Light Water Reactor Inspection Program-Construction Phase
(construction inspection program) and to make an overall assessment of
the adequacy of Region V's oversight of construction activities at the
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Palo Verde Unit 3 site.
The Construction Appraisal Team (CAT) of the Division of Inspection
Programs conducted an announced construction inspection at the Arizona
Nuclear Power Project's Palo Verde Unit 3 site during the period of
January 13-24 and February 3-14, 1986. While the predominant effort of
the inspection team was devoted to hardware inspection, the team also
evaluated the control of design changes and corrective actions.
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II. ASSESSMENT ACTIVITIES
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A review was made of Region V inspection reports of the Palo Verde Unit
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3 site, SALP reports, and construction deficiency reports to identify
those deficiencies that were previously identified by Region V inspec-
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tors or *he licensee.
The review included inspection reports of approxi-
mately 1980 to 1985, applicable open items and violations and SALP reports
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for July 1981 - February 1983, March 1983 - March 1984, and April 1984 -
September 1985.
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To determine the inspection effort at Palo Verde Unit 3, the inspection
reports for 1975 through 1985 and the 766 Computer System inspection data
were analyzed.
It was determined that Region V performed a total of
3990 manhours (January 1,1975 - December 31, 1985) of direct inspection
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effort at Palo Verde Unit 3 as documented in the 766 System on March 20,
1986.
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The site total construction inspection hours were compared to other sites
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(Catawba Unit 2, Byron Unit 2, and Palo Verde Unit 2) considered to be in
a similar stage of construction and the manhours were found to be
comparable, thus indicating a satisfactory level of inspection effort at
the site. Attachment I graphically depicts the comparison of inspection
hours. The analysis of the inspection reports and 766 Computer System
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data indicated that the construction inspection program was approximately
90-95 percent complete at the start of the CAT inspection.
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It should be noted that two sets of inspection hours are referenced in
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this assessment due to the time frame in which the data was obtained from
the 766 data system.
Both sets are consistent, however, one set has been
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used to compare other similar sites and the other is used in
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assessing the inspection program effort solely at Palo Verde Unit 3.
The Executive Summary and Potential Enforcement Actions of the Palo Verde
Unit 3 CAT inspection report (50-530/86-03) are provided as Appendix A
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and Appendix B, respectively.
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III. ASSESSMENT FINDINGS
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A.
Electrical and Instrumentation Construction
1.
CAT Findinas
The NRC CAT identified a number of raceway installations
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that did not meet the specified separation criteria.
The
licensee's inspection program for separation had not been
completed, so its adequacy could not be evaluated.
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Configuration deficiencies in welded connections were
identified by the NRC CAT in some cable tray hanger
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connections and in the mounting of a large proportion of
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electrical equipment.
Previously, several reinspections
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had been conducted by the licensee for various aspects of
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cable tray hangers.
The quality of vendor terminations in the diesel generator
control panels and soldered connections in the 125V de
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battery chargers were found to be inadequate.
The QC verification of in process excore cable terminations
was found to be inadequate.
The qualification for several components in the diesel
generator control panels and certain wire types in motor
operated valves requires additional review.
2.
Assessment
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The Region documents raceway inspections for Unit 3 in two
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Inspection Reports, 50-530/85-09 and 50-530/85-18, with no
significant findings.
The Regional reports cover 21 cable
tray runs and 4 conduit runs (less than half that reviewed
by the NRC CAT).
The Region's sample did not coincide with
the NRC CAT's inspection sample.
It is noted that of the
18 cable tray runs inspected in Inspection Report 50-530/
85-18, only 3 are identified as Class 1E installations.
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The Regional CAT (50-528/83-34) conducted for Unit 1
inspected a much larger sample of racewa
several isolated separation violations. y and identified
The Region's
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conclusion that raceway separation is not a prob 1 w. is
understandable based on the sample inspected.
Thirty pieces of electrical equipment including 19 panels
were inspected by the Region and the results reported in
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Inspection Report 50-530/84-03.
Only two items coincided
with the NRC CAT sample, these were not ones with which the
NRC CAT had identified mounting deficiencies. The Region
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had previously identified main panel mounting weld defi-
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ciencies in Unit I and the results reported in Inspection
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Report 50-528/82-25.
Both the' Region's previous findings
in this area cnd the high proportion (16 of 38) of items
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identified by NB the NRC CAT and the licensee, seem to
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indicate that similar deficiencies in this area should have
been found by the Region's sample,
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Only three cable tray supports are documented as being
inspected by the Region and IE personnel in Unit 3
(Inspection Report 50-530/85-09).
These supports were not
in the same plant areas as the five hangers with mounting
configuration problems identified by the NRC CAT.
However,
the Regional CAT conducted in Unit 1 did identify similar
weld configuration problems for hanger braces and Inspec-
tion Report 50-530/85-29 documents a record review of the
cable tray hanger reinspection efforts.
The 30 electrical items inspected by the Region, as
reported in Inspection Report 50-530/84-03, did include two
battery chargers, but did not include any of the emergency
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diesel generator control cabinets.
Neither the current
inspection procedure nor the procedures used by the Region
include specific requirements for inspection of vendor
installed wiring or components.
As such, the Region's
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inspection would not be expected to have identified the
vendor quality problems found by the NRC CAT in the battery
chargers or the diesel generator control panels.
The Region has inspected approximately 50 cables and as
many terminations for in process and final installation aad
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have closed the applicable work observation inspection
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procedures.
Their findings are consistent with and sup-
ported by the limited NRC CAT sample.
The inspection of
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excore termination activities, found deficient b
CAT, was ongoing during the NRC CAT inspection. y the NRC
The Region
had not yet performed any inspection of these activities.
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Instrumentation construction has been inspected by the
Region and reported in four Inspection Reports
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(50-530/84-07,84-12,85-20 85-29
tion findings in this area a,re cons).
The NRC CAT inspec-
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istent with the Region's
findings.
3.
Recommendations
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The Region's implementation of the construction inspection
program in this area has been satisfactory.
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The Region should place more attention in selecting for
examination primarily saftty-related components for which clear
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regulatory requirements exist.
In addition, several CAT inspection followup areas are recom-
mended for future Regional emphasis.
These are:
verification
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of the adequacy of the licensee's raceway separation inspec-
tions, verification of the licensee's corrective action for
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equipment mounting, and verification of adequate documentation
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for environmental qualification of wiring in motor operated
valves.
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B.
Mechanical Construction
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1.
CAT Findings
The NRC CAT identified three instances of improper bolting
material for piping flanges.
The NRC CAT identified several instances of potential pipe
and pipe support interferences with adjacent structures
and components.
Undersized beam attachment load pins were found by the NRC
CAT to be used on pipe supportsfrestraints.
The NRC CAT identified numerous instances of loose,
missing or ineffective locknuts, cotter pins and locking
rings on pipe supports / restraints.
2.
Assessment
The various Region V inspections in the area of piping
have generally focused on welded pipe joints and piping
system configuration rather than bolted flange connections
or iriterferences.
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The Region has reviewed at least 47 supports in Unit 3
(Inspection Reports 50-530/82-09, 84-07, 84-08, and 85-23)
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and additional supports in Unit 1 in the Regional CAT
inspection in 1983.
Although welding and configuration
deficiencies were identified, no discrepancies were identi-
fied in pipe support load pins.
The Region's sample of
pipe supports inspected were not the same as those chosen by
the NRC CAT.
Therefort, it is understandable that the
Region had not identified this deficiency previously.
In the area of ineffective locking devices, the Region V
CAT inspection had identified this issue also. As a result
of the Regional CAT finding CAR S-83-56 was issued and a
reinspection program initiated.
This issue was closed in
Inspection Report 50-530/84-16 bassJ the licensee's broad
corrective actions.
However, based on the NRC CAT find-
ings, it appears that the licensee's corrective actions
have not been fully effective.
This issue of locking
devices seems to be one which continues to affect most
construction sites until the final construction stages and
work is essentially complete.
Although the issue is not
technically significant, additional licensee and Regional
attention will be necessary to assure that the issue is
satisfactorily resolved.
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3.
Recommendations
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In the area of bolted flange connections, piping system
interferences, and locking devices the Region should place
additional attention to ensure adequate inspection: coverage
and followup to the NRC CAT findings.
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In the area of pipe support load pins the Regional inspec-
tion performance is considered satisfactory.
C.
Welding - NDE
1.
CAT Findings
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Several examples were found by the NRC CAT in which
completed structural welds in pipe supports / restraints
were smaller than specified in the design drawings.
1he NRC CAT identified deficient welds in vendor supplied
instrument racks.
A number of radiographs were found which did not have the
required film quality.
The NRC CAT identified welds which had indications that
were not recorded as required by the licensee's Preservice
Examination (PSE) program.
The NRC CAT had several questions with regard to whether
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some welding procedures adequately addressed ASME Code
provisions.
2.
Assessment
In the area of pipe support welding, the region has perfor-
med inspections of at least 47 supports (Inspection Reports
50-530/82-09, 84-07, 85-08, and 85-23) in Unit 3 and also
additional supports were inspected as part of the Regional
CAT inspection of Unit 1 in 1983.
The Regional CAT also
identified weld defciencies in pipe supports. The licen-
see's corrective actions to the Regional CAT findings
included a reinspection of a large sample of supports and
additional training and guidance for QC inspectors and
Field Engineers.
It was not determined whether the welding
deficiencies identified by the NRC CAT had occurred before
or after the reinspection and training activities.
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With regard to the weld deficiencies identified in instru-
ment racks, the applicable inspection reports (50-530/
84-07, 84-12, 85-20, and 85-29) were reviewed and found to
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address instrumentation installation and cable activities
including receiving inspections but not an independent
inspection of vendor supplied components.
The receiving
inspection records for two instrument ra-ks (not ones found
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deficient by the NRC CAT) were inspected and documented in
Inspection Report 50-530/85-20; however, the actual instru-
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ment rack hardware was not inspected.
In a related area of
vendor supplied equipment (fuel storage racks), -5e racks
were inspected by the Region and found to have wd discre-
pancies (Inspection Report 50-530/85-09).
The Region's inspections seem to have been performed in
accordance with the guidance provided in the applicable IE
inspection procedures.
The NRC CAT findings in the area of vendor radiographs not
meeting applicable requirements involved vendor supplied
components (shutdown heat exchangers and transfer tube-
housing).
The Region's focus of welding inspections
generally followed the prescribed activities in the inspec-
tion procedures.
The inspections were generally in the
area of piping and steel structures for on-site welding
activities.
The Regional CAT inspection did review vendor
radiographs; however, the radiographs selected were from
piping systems and not other types of components.
The Region has reviewed the area of PSE for Unit 3 in
Inspection Report 50-530/84-06.
In the area of PT examina-
tions in which the NRC CAT identified deficiencies, the
Region had witnessed PT examinations with no deficiencies
identified.
The Region's sample was not the same nor as
extensive as the NRC CAT inspection.
With regard to the NRC CAT questions on some welding
procedures, the Region had reviewed some of the same
welding procedures in Inspection Report 50-530/85-30 and
50-530/81-02.
Three of the seven welding procedures
reviewed by the Region were also reviewed by the NRC CAT.
The Region had not identified any deficiencies in the
welding procedures; however, the NRC CAT did identify
questions with regard to meeting the Code provisions for
impact tests done for procedure qualification and the
identification of nonessential variables.
It appears that
the Region had reviewed the appropriate procedures and
associated records; however, the inspector did not
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describe in the inspection report how Code compliance was
met.
3.
Recommendations
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Regional inspection:, were effective in identifying deficiencies
similar to those of the NRC CAT in pipe support welding.
The review of the Region's inspection of welding procedures
(the most recent one done one month before the NRC CAT inspec-
tion) indicates that the Region needs to describe in more detail
how code provisions are being met especially for circumstances
in which the normal or more routine Code criteria are not being
Although no violation of Code provisions were idem.if ted
met.
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by the NRC CAT, a complex process was involved to ascertain Code
compliance.
D.
Civil and Structural Construction
1.
CAT Findings
Deficiencies were identified by the NRC CAT in the design,
construction, and inspection of masonry block walls.
The root
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cause of the deficiencies appear to be the incorrect quality
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classification orginally applied to these block walls.
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2.
Assessment
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The Region's inspections in the civil construction area
covered the areas of geotechnical, structural concrete,
containment post-tensioning, and structural steel. A
review of the inspection reports and 766 system data in
this area shows satisfactory performance of the
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construction inspection program.
The Regional inspection (Inspection Report 50-530/83-06)
related to masonry walls was only to document the closure
of IE Bulletin 80-11 based on continuing correspondence
between NRR and the licensee associated with the NRR
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generic letter requesting design information from the
licensee.
The Region performed essentially no inspection
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of masonry walls at Palo Verde.
This is understandable for
a number of reasons.
First, the origin of the issue of
masonry walls was with IE Bulletin 80-11, which was addres-
sed only to operating facilities.
Construction sites were
to be included during the on going licensing review pro-
Although guidance for the inspection of IE Bulletin
cess.
80-11 was issued, the inspection guidance was not appli-
cable to construction sites.
Second, at the time of the
issuance of the NRR generic letter, NRR had not yet fully
developed the full acceptance criteria nor the full range
of design criteria to be addressed by the licensee (as now
established in the Standard Review Plan).
The Standard
Review Plan now requires the licensee to describe the
applicable QA/QC criteria used in the construction of
masonry walls.
Third, IE inspection procedures do not
address masonry construction.
In summary, as specific
guidance had not been provided to the Region for the
inspection of masonry construction, it is understandable
why this area did not receive Regional inspection atten-
tion.
3.
Recommendation
Generally the Region's implementation of the inspection program
in the civil area hat been satisfactory.
The Region should
continue to monitor the status of the masonry wall issue being
discussed between NRC and the licensee relating to Units 1, 2,
and 3.
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E.
Material Traceability and Control
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1.
CAT Findings
No significant deficiencies were identified in this area.
2.
Assessment
The Region has generally reviewed the area of material trace-
ability as part of inspections in the technical areas (i.e.,
mechanical, electrical, welding, and civil / structural).
In
addition, the overall area was reviewed in Inspection Report
50-530/81-02.
Based on the lack of significant findings in
this area, it appears that the Regional inspection effort has
been effective in ensuring adequate licensee performance in the
area of material traceability.
3.
Recommendations
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No recommendations are necessary at this time.
F.
Design Change Control
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1.
CAT Findings
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A number of Field Change Requests (FCRs) appeared to have
an inadequate description of the reason (justification) for
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the design change.
It was noted that ANPP Internal Proce-
dures Manual provides no guidance on when documented
justification for design changes is required, except for
changes affecting Pipe Stress and Supports (PS&S) calcula-
tions.
A similar finding had been made during at least one
licensee audit as reported in Corrective Action Report No.
CA-84-0351, Aprii 22, 1985.
Several instances were identified in which a design charge
was made and referenced to a specific design document
without changes being made to other affected design docu-
ments.
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2.
Assessment
The Regional inspections in this area (Inspection Reports
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50-530/81-02, 84-04, and 84-07) generally identified no signifi-
cant deficiencies, except some in the N-5 program. The joint IE
and Region V inspection (Inspection Report 50-530/85-09) identi-
fled similar deficiencies as the NRC CAT inspection.
The NRC CAT and joint IE and Region V inspections did concen-
trate efforts specifically in the design change area and
reviewed substantially more design change documents than the
Region.
The magnitude of the deficiencies identified by the
NRC CAT in this area is not considered to be significant.
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Therefore, based on the above, it is reasonable to expect that
the Region would have concluded that there were no significant
deficiencies in the design change area.
3.
Recommendations
The Regional inspection efforts are considered satisfactory in
this area, therefore no recommendations are made at this time.
G.
Corrective Action Systems
1.
CAT Findings
No significant deficiencies were identified by the NRC CAT in
this area, except in the area of cable tray hangers which is
discussed in Section III.A above.
2.
Assessment
The Region has periodically reviewed the licensee's Corrective
Action programs by various approaches (i.e. , QA program
reviews, followup to Notices of Violation, followup to licensee
identified items and followup to licenrec audits and
surveillances). ,The Region appears to .iave been effective in
assuring adequate licensee performance.
3.
Recommendations
No recommendations are made at this time.
IV.
REVIEW OF CONSTRUCTION INSPECTION PROGRAM AT PALO VERDE UNIT 3
A.
Scope
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Inspection staff hours for Palo Verde Unit 3 reported to the 766
system starting January 1,1975 through December 31 1985 and
existing in the system as of March 20, 1986,
with inspection report numbers, inspection dates, inspectionwere
procedures used, and data on completion and status.
The above data
is sumarized in Attachments II and III.
Attachment II contains a
summary of the inspection staff hours and completion status of the
MC 2512 construction inspection program for Palo Verde Unit 3 and
Attachment III is a more detailed presentation of the inspection
history by technical areas developed from the 766 system data base.
A sampling of inspection reports prepared by the Region were
evaluated with respect to content, timely issuance and overall
completeness.
The total inspection hours discussed in this section are slightly
different than those discussed in Section II above due to the
difference in dates that the 766 system information was requested.
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B.
Assessment
A distribution of inspection procedures by the reported degree of
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completion (Section A of Attachment II) indicates that the construc-
tion inspection program for Palo Verde Unit 3 is comparable to the
construction status of the site.
Eighty-three percent of the MC 2512
procedures are closed at 100 percent completion with only seven
percent of the procedures between 26 and 99 percent complete.
Our evaluation shows a total of 3990 staff hours in the 766 system
(as of March 29,1986) devoted to construction inspection of Palo
Verde Unit 3.
The hours have been grouped into 17 inspection areas
(Section B of Attachment II).
The breakdown of inspection hours into
inspection areas indicates most areas have had adequate attention
with a fairly equitable distribution of effort. However, it also
indicates two areas which may warrant additional attention by the
Region to determine whether inspection efforts have adequately
covered tne area.
In the areas of containment penetrations and
inservice and preservice inspection it appears that the inspection
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hours expended thus far are relatively low in comparison with the
plant's construction status.
The contributions of the CAT inspection
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in these areas should improve the number of inspection hours
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reflected in the 766 system. These findings have been discussed with
the Regional Office and they have generally acknowledged them and will
be evaluating their records to ensure inspection coverage.
The listing of 15 significant inspection procedures with no hours
charged against them (Section C of Attachment II) shows that five of
the procedures have been closed by the Region. This seems to indi-
cate that the Region has evaluated the requirements for these proce-
dures and has determined that the requirements have been satisfied.
It was noted that the four instrumentation cable procedures with no
hours include those for procedures and records review and one proce-
dure for the work observation inspection.
Our review of Inspection
Report 50-530/84-07, shows that procedures had been reviewed, however
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the procedures and records reviews were documented against the
electrical cable procedures, rather than instrumentation.
With respect to the division of staff inspection hours into the
three major inspection areas of program / procedure review, work
observation, and record review, the majority was devoted to work
observation (65% of the inspection hours), while 9% and 25% were
spent on procedures and records respectively (Section D of Attachment
II). The percentages are as expected due to the desired emphasis on
work observation and the fact that procedure reviews for later units
of a multi-unit site would generally be for changes to the proce-
dures.
The review of the inspection reports for Palo Verde Unit 3 indicates
generally 9000 conformance with MC 0610 in terms of content, timeli-
ness of report issuance and overall completeness. A review of a
sample of reports issued over the past year (1985) indicates that
the reports are well written and detailed and have adequate technical
depth. It was noted that the inspection reports now include a
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description of the applicable inspection procedures as suggested by
MC 0610 and last year's regional assessment.
In addition, the
inspection reports generally provide clarification on which unit or
units is being referenced (an exception being Inspection Report
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50-530/85-14, which does not clearly define the applicable unit,
A
check of 12 inspection reports (regional and resident inspector
inspections) shows an average of 18 days for issuance of the report.
This is within the 20 day guideline stated in MC 0610.
This is a
marked improvement from last year's assessment which found that
average to be 39 days for report issuance.
We note in our review of some electrical and instrumentation
inspection reports that the sample of components to be inspected
have not been as expected.
Inspection Reports 50-530/84-12, 85-18
and 85-20 describe 18 cable tray segments reviewed, however 15 were
non-Class IE installations and 21 HVAC instruments inspected with 10
being aonsafety related.
Also, the instrumentation selected in
safety-related applications have been only in the HVAC area.
We
note also that the inspections in the instrumentation area are not
yet completed.
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C.
R_ecommendations
The information reviewed, which was current as of March 20, IL6,
indicates that the Region has generally followed the construction
inspection program in MC 2512.
Weaknesses discussed in last years
assessment seem to have been effectively corrected. We note that
two areas may require additional Regional inspection attention
(containment penetrations and inservice and preservice inspection).
In the electrical and instrumentation area, the selection of compo-
nents to be inspected should be focused more towards safety related
items and a broader category of instrumentation.
V.
SALP REPORTS
An analysis was made of the three most recent SALP reports, for the
periods July 1981 - February 1983, March 1983 - March 1984, and April
1984 - September 1985, for those areas that were common to both the SALP
and CAT inspection.
It was noted that the SALP ratings did not distin-
guish between the units at the Palo Verde site.
Generally, the licensee
has been rated by the Region as Category 2 in the construction areas with
only one Category 3 rating (in support systems) and six Category 1 ratings
for the three SALP periods reviewed (a total of 20 individual ratings).
Generally, the CAT inspection findings are consistent with and reinforce
the latest SALP ratings and recommendations in the construction area.
This was particularly evident in two areas.
In the area of the thorough-
ness of engineering evaluations, the NRC CAT also noted a lack of compre-
hensiveness in the evaluation of welding deficiencies for the mounting of
electrical panels and also in the lack of technical justification for
several design changes.
In the area of attention to subcontractors, the
NRC CAT did identify several vendor supplied equipment deficiencies,
i.e. , deficient welding on instrument racks, poor radiography quality and
documentation, and inadequate electrical panel terminations.
- 11 -
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1
i
.
In one area there appears to be based on the CAT findings, a declining
trend which may require additional licensee and Regional attention.
The
NRC CAT has identified several deficiencies in the piping and pipe support
area which were not previously identified by the licensee.
These defi-
ciencies were undersized load pins on pipe supports; improper bolting
materials in piping flanges; unrecorded indications in the Preservice
Examination program; and questions relating to the adequacy of some
Bechtel welding procedures.
It is noted that the Region has expanded 601
.
hours of inspection in this area (Units 1, 2, and 3).
The Region should
continue to closely monitor activities in this area.
In the area of Support Systems, it was noted that the 1981-1983 SALP Board
had recommended increased NRC inspection in the HVAC area.
During the
SALP period some portion of 115 hours0.00133 days <br />0.0319 hours <br />1.901455e-4 weeks <br />4.37575e-5 months <br /> had been devoted to HVAC inspection.
In the next SALP period, March 1983 - March 1984, although the SALP
reports only one inspection was performed in this area,164 hours0.0019 days <br />0.0456 hours <br />2.71164e-4 weeks <br />6.2402e-5 months <br /> of
inspection were expended.
Based on this inspection and the indication of
a lack of effective corrective actions, the licensee was given d Category
3 assessment. The next SALP report for April 1984 - September 1985, shows
j
207 inspection hours in this area during this period.
However, it appears
that the evaluation of the licensee's performance in this area was based
on an incorrectly assumed Category 2 rating in the previous SALP period,
i
The actual rating had been Category 3.
The NRC CAT findings in this area
indicated no significant deficiencies.
Based on the NRC CAT findings in
this area, it appears that the Region has been effective in obtaining
satisfactory licensee performance.
However, the Region s ould pay closer
attention to previous SALP ratings to ensure an accurate appraisal and the
identification of trends.
]
,
VI.
REGIONAL ASSESSMENT OF 198y
The Region was provided an assessment last year in a memorandum from J.
Partlow to D. Kirsch dated June 19, 1985.
This assessment reviewed the
implementation of the construction inspection program at Palo Verde Unit
3 for the period February 1984 through March 1985.
The Region's implemen-
tation of the inspection program was considered acceptable, however, a few
items required additional Regional attention or evaluation.
l
Our review of the inspection reports and 766 data shows that the Region
has markedly improved their inspection performance and has generally
{
satisfied the comments and suggestions of the June 1985 assessment.
Specifically, the Region addressed the assessment comments as follows:
,
)
l
(1) Inspection procedures were reviewed and followup inspections
conducted where necessary for those cases in which inspection credit
for Unit 3 were taken for inspections conducted for Unit 1 or 2;
(2) Increased inspection coverage was accomplished for the period
February-September 1985 (927 inspection hours documented);
(3) The documented use of the current inspection procedures has
increased;
i
(4) Inspection reports are being issued in a timely manner generally
within the guidelines of MC 0610; and
i
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_ _ . . _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _
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(5) The inspection reports are now referencing the applicable inspection
procedures and unit being inspected against.
VII. OVERALL ASSESSMENT CONCLUSIONS
A review of the Palo Verde Unit 3 inspection reports, SALP reports, and
766 Computer System data indicates that generally the construction inspec-
tion program and inspection procedures have been satisfactorily imple-
mented. Overall the inspection reports were well written with the neces-
sary scope, depth, and technical content and on the average were issued
within the suggested time period.
In one instance it was noted that the
inspection findings were not well documented to be able to evaluate how
,
ASME Code requirements were being met.
In addition, the Region should pay
closer attention to the sample selected for inspection to ensure that the
j
sample is primarily safety related installations and that instrumentation
is selected from the various process systems.
Two areas require additional
l
i
attention to ensure that inspection procedures in the areas of containment
penetrations and in-service / pre-service inspection have, or will, receive
adequate inspection coverage.
During our review of the Region's implementation of the IE construction
inspection program, the inspection program procedures were informally
evaluated.
In general, the inspection procedures were adequate, however,
the CAT findings suggest additional refinements.
Specifically these
(1) in the electrical area, review of vendor workmanship in instal-
are:
l
led equipment; (2) in the welding /NDE area, review of vendor supplied
components; and (3) in the civil area, review of masonry wall construc-
tion.
i
The review of the CAT and Regional inspection findings shows general
agreement.
It is recommended that the Region place additional attention
on the corrective actions to the NRC CAT findings in the areas of electri-
I
cal raceway separation, electrical equipment mounting, and masonry walls.
A review of the three most recent SALP reports indicates that the CAT
inspection findings are consistent with and reinforce the latest SALP
i
ratings and recommendations in the construction area. The four CAT
findings in the area of piping and pipe supports seem to indicate that
closer attention by the Region and licensee may be necessary.
The Region
should pay closer attention to previous SALP ratings to ensure accurate
{
appraisals and identification of trends.
The Region has satisfactorily implemented the recommendations and comments
of last year's assessment.
The Region's efforts were clearly evident in
our review of inspection reports and the 766 system data.
Overall, the Regional efforts to oversee the construction activities of
Palo Verde Unit 3 are satisfactory and the implementation of the inspec-
tion program procedures was also satisfactory.
i
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.
APPENDIX A
EXECUTIVE StM4ARY
An announced NRC Construction Appraisal Team (CAT) inspection was conducted at
Arizona Public Service Company's Palo Verde Nuclear Generating Station (PVNGS)
Unit 3 during the period January 13-24 and February 3-14, 1986.
OVERALL CONCLUSIONS
-
Hardware and documentation for construction activities were generally in
accordance with requirements and licensee commitments. However, the NRC CAT did
identify a number of hardware deficiencies that in most cases have resulted from
construction program weaknesses. These include:
1.
Masonry walls which support and are adjacent to safety-related components
were found by the NRC CAT to have the reinforcing bars not placed in accord-
ance with the design drawings.
In addition, prescribed inspection records
we n not available to document the adequacy of the masonry wall construction
proevss and to support design analysis assumptions. This was due in part to
the fact that the origir,al quality classification of the masonry walls was
incorrect. The masonry walls were classified as Class S which requires no
special quality requirements beyond industry standards. This area will
require further review by the NRC.
2.
In the mounting of electrical components, 6 of 11 pieces of QC accepted
equipment and 5 of 32 QC accepted cable tray hangers were found with weld
configurations that did not match specified requirements.
In addition,
the cable tray hangers had been subject to plant wide reinspection programs
for previously identified attachment design deficiencies.
I
3.
Based on field observation of work activity, discussions with site
engineering and Westinghouse personnel, and a review of data which
describes failures and detector leakage experienced on PVGNS Units 1
and 2, NRC CAT inspectors concluded that the existing quality verification
program was not adequate to assure that critical ex-core termination
activities are satisfactorily accomplished. Based upon NRC CAT concerns,
the applicable QC procedure was revised to specifically detail those
i
steps for which QC inspection is required.
4.
Several deficiencies in vendor equipment were identified. These were vendor
deficiencies related to terminations in the diesel generator control panels
and soldered connections in the 125V DC battery chargers and had not been
identified during source inspection, receipt inspection, or field installa-
tion activities.
In addition, vendor weld deficiencies were found in
instrument racks.
AREAS INSPECTED AND RESULTS
Electrical and Instrumentation Construction
In general, the electrical and instrumentation in'sta11ations examined were found
to confors to applicable design and installation requirements. However, several
areas with hardware deficiencies were identified.
A-1
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__
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- - - . - .
.
. -
.
. . .
e
.
.
A number of raceway installations were found not meeting the required separation
criteria. However, the major efforts of the licensee's inspection program for
separation of Class 1E raceway installations is not
This area
will require additional.NRC and licensee attention. yet complete.
Configuration deficiencies were identified in some cable tray hanger connections
and the mounting welds for some electrical panels.
Five QC accepted cable tray
hangers were found with weld connections not matching the configuration of
approved designs. A large percentage (6 of 11 panels inspected) of QC accepted
equipment was found to exhibit deficient mounting configurations. The mounting
weld configurations were not in accordance with the approved design documents.
The quality of vendor terminations it, the diesel generator control panels and
i
125V de battery chargers was found to be inadequate.
The field QC verification of in process excore terminations was found to be
1
inadequate and requires additional licensee attention.
The status of qualification for several components of the diesel generator control
panels and some wire types in motor operated valves requires additional NRC and
l
licensee review.
Mechanical Construction
Preventive maintenance of mechanical equipment was found to be in conformance
with requirements and good maintenance practices. Heating, ventilating and air
conditioning hardware (supports / restraints, duct sections, fire dampers) were
generally found to be installed in accordance with requirements or the deficien-
cies found by the NRC CAT had been previously identified. However, deficiencies
were identified in three areas: piping, pipe supports / restraints, and mechanical
equipment.
In the area of piping, improper material was used for flange bolting.
Undersized beam attachment load pins were used on pipe supports / restraints.
Mounting hardware and foundations on some HVAC equipment were found to be
-
j
fabricated and installed improperly. These areas of concern require further
i
licensee evaluation.
Weldino and Nondestructive Examination
Welding and nondestructive examination activities were generally found to be
conducted in accordance with the governing codes and specifications.
However,
several examples were found in which completed structural welds in pipe supports /
restraints were smaller than that specified in the design drawings. Some vendor
supplied tanks and heat exchangers were found to have undersized weld reinforce-
ment in "nozzle to shell" and sanway to shell" joints.
In addition, deficient
welds were found in vendor supplied instrument racks.
The NRC CAT inspectors also found a number of vendor radiographs which did not
have the required fils quality.
In the area of Preservice Examination activities,
the NRC CAT identified welds which had indications that had not been recorded as
required by the licensee's program.
In the review of some wlding procedures, timely information was not provided
to adequately determine whether the procedures property addressed ASME Code
provisions in the areas of impact tests of the heat affected zene, the identi-
fication of non-essentiel welding variables, and the prohibition of peening in
certain situations.
A-2
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,
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.
.
. .
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- _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ __
.
.
Civil and Structural Construction
In the area of masonry block walls, the NRC CAT identified that prescribed
in-process inspections had not been perfomed.
It was also identified that
reinforcing bars were not positioned as required by the design drawings.
The design and construction adequacy of the block walls will require further
.
review by the NRC.
Structural steel installation was determined to be generally adequate. Deficient
bolted connections were found by the. NRC CAT in containment column splice
connections. Design considerations for thermal loading on structural steel
members will require further review by the NRC.
QC documentation for concrete placements, mechanical splices of reinforcing steel,
containment post-tensioned tendons, and structural backfill were generally deter-
ained to be adequate.
Material Traceability and Control
The material traceability and control program is considered 'to be satisfactory.
No significant deficiencies were idsntified in the sample of items selected for
review by the NRC CAT. Documentation was available to indicat. that materials
were installed as specified.
Design Change Control
Design change control was determined to be generally in conformance with
applicable requirements. The most significant findings were the lack of docu-
mented, auditable justification for some safety-related design changes and failure
to assure that design changes were made to all affected design documents in a
timely manner.
Corrective Action Systems
In general the licensee's corrective action program was found to be acceptable.
However, in the area of cable tray support attachment configuration the licen-
see's program has not been effective as evidenced by additional examples of
configuration deficiencies found by the NRC CAT after several licensee
reinspection programs.
.
A-3
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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
i
.
APPENDIX B
POTENTIAL ENFORCEMENT ACTIONS
As a result of the NRC CAT inspection of January 13-24 and February 3-14, 1986
,
at the Palo Verde site, the following items are being referred to Region V as
Potential Enforcement Actions.
Section references are to the detailed portion
of the inspection report.
.
1.
10 CFR 50, Appendix B, Criterion III, as implemented by Arizona Public
Service (APS), Palo Verde Nuclear Generating Station Final Safety
Analysis Report (FSAR) Section 17.1A.3, requires that measures shall.be
established to assure that applicable regulatory requirements and design
basis are correctly translated into specifications, drawings, procedures,
and instructions.
Contrary to the above, at the time of this inspection, the licensee's program
was not adequately implemented in that masonry block walls were incorrectly
classified as Quality Class S for which no special quality requirements
beyond industry standards are needed.
Partially due to the "S" quality
classification, in process inspections were not accomplished. As a result,
reinforcing steel was found to be located not in accordance with the design
drawings and also inspection records were not available to support design
analyses assumptions. Therefore, masonry walls may not meet their design
intent.
(Section V.B.1)
2.
10 CFR 50, Appendix B, Criterion VII, as implemented by the APS FSAR
Section 17.1A.7, requires in part that measures shall be established to
assure that purchased material, equipment, and services conform to purchase
documents.
Contrary to the above, at the time of this inspection, the NRC CAT inspec-
tors found several deficiencies in vendor supplied components as follows:
Several installed Class 1E components exhibited poor workmanship and
a.
inadequate vendor product quality. These include inadequate solder
connections in the de ba'ttery chargers and damaged and broken terminal
lugs in the diesel generator control panels. (Sections II.B.2.b(4) and
II.B.3.b.(6))
l
.
b.
Instrument racks had various weld deficiencies such as incomplete
fusion, missing or undersized welds, and weld spatter. (Section IV.B.5)
Some vendor supplied radiographs did not have the required fils quality.
c.
(SectionIV.B.11)
3.
10 CFR 50, Appendix B, Criterion X, as implemented by the APS FSAR
Section 17.1A.10, requires that a program for inspection of activities
affecting quality be established and executed to verify conformance with the
documented instructions, procedures, and drawings for accomplishing the
activity.
,
,
Contrary to the above, at the time of this inspection, the licensee's
inspection programs were not effectively implemented in that:
b-1
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1,1
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.
.
$
a.
Four instances of undersized beam attachment load pins were identified
on two ASME Class 1 pipe supports and two Class R pipe supports contrary
to design drawings and vendor catalogs.
(Section III.B.2)
b.
Improper bolting materials were identified on flange connections in
piping installations.
(Section III.B.1)
c.
Six of eleven pieces of QC accepted Class 1E equipment sounted by
welding had mounting configurations which were not in accordance with
the applicable design or specified installation requirements.
In
.
addition, 5 of 32 QC accepted cable tray hangers were found with welded
connection configurations that were not in accordance with the appli-
cable installation requirements.
(Sections II.B.1.b.(3), II.8.3.b.(4),
(6) and (7))
i
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_ , _ _ . _ _ - . _ _ _ _ . . _ _ . .
. _ _ _ _ .
MC 2512 INSPECTION HOURS
COMPARISON OF PV-3 TO OTHER PIANTS
7-
6692
g
6-
D
5-
(4845 Avg)
,
-
,
o_
2-
- ~2MMM
PV-2
PV-3
B-2
C-2
COMPARISON PIANTS
PV-2
Palo Verde 2
B-2
Byron 2
PV-3
Palo Verde 3
C-2
Catawba 2
,
.
ATTACHMENT II
766 DATA SUMMARY
MC 2512 STATUS OF PALO VERDE UNIT 3
Summary of Inspection Procedures (IPs) used versus procedures specified in MC 2512, and staffhours expended and distributions.
Based on 766 Computer System
data as of March 20, 1986.
A.
Distribution of IPs by Degree of Completion
Percent Completion
No.
Percent
Less than 25%
14
11
26-50%
4
3
51-75%
2
2
76-99%
2
2
100%
102
83
124
101 (due to rounding error)
B.
Total Hours per Inspection Area for MC 2512
Inspection Area
Hours
Percentage
Management Meetings
139
3
Quality Assurance
144
4
Design and As-Built
270
7
Geotechnical
34
<1
Structural Concrete
132
3
Structural Steel / Supports
154
4
Piping
187
5
Mechanical Components
504
13
Electrical
413
10
Instrumentation
186
5
Containment Penetrations
29
<1
Welding /NDE
263
7
Containment Test
0
0
Inservice and Freservice Inspection
38
1
Followup
661
16 .
Independent Inspection
811
20
Miscellaneous
25
<1
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11-1
_ _ _ _ _ _ _ -
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-.
1
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.
.
C.
Significant IPs with no Hours Reported
Management Meetings
30051B*
Structural Concrete
47061B*
Mechnical Components
500558
500618
50065B
50074B*
Instrumentation
52061B
52064B
52065B
52066B
Welding and NDE
55071B
55073B
55171B*
55178B*
Containment Test
63050B
,
- These IPs are reported to be 100 percent complete and closed with no
inspection bours.
This indicates completion of the inspection
requirements through a different basis.
D.
Number of Phase 2 (Construction) IPs Used and Total Hours
Program
No. of IPs Used
Total Inspection Hours
136
3990
IP Scope
Hours
Percentage
Procedure Review
174
9
Work Observation
1211
65
Records Review
469
25
1554
~II-(due to rounding error)
I
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ATTACHMENT III
INSPECTION PROGRAM HISTORY FOR PALO VERDE 3
(JANUARY 1,1985 - DECEMBER 31, 1985)
'
A.
Civil and Structural Procedures
Reported
Procedure
Number of
Total Staff
Percent
Reported
Number
Inspections
Hours
Completion
Status
1.
Geotechnical
45051B
1
4
100
C
45053B
1
3
45055B
2
17
100
C
46051B
1
1
100
C
)
46053C
3
8
100
C
46055B
1
1
100
C
]
2.
Structural Concrete
47051B
4
17
100
C
'
47053B
5
26
100
C
47053C
10
39
,
47054B
3
14
100
C
47055B
4
10
100
C
i
47056B
1
2
100
C
47061B
1
100
C
-
47063B
1
17
90
l
47063C
1
3
100
C
'
47065B
1
4
100
C
3.
Structural Steel / Supports
48051B
2
4
100
C
480538
4
19
75
C
43053C
8
29
48055B
2
43
100
C
48061B
1
1
100
C
48063B
1
6
100
C
48063C
2
4
48064B
1
6
100
C
480658
2
42
100
C
d
III-1
.
B.
Mechanical Construction Procedures
Procedure
Number of
Total Staff
Percent
Reported
Number
Inspections
Hours
_ Completion
Status
1.
Piping
49051B
1
2
100
C
49053B
2
56
100
C
49054B
1
8
100
C
49055B
1
19
100
C
49061B
1
2
100
C
490638
4
44
100
C
49063C
4
14
49065
1
42
100
C
2.
Mechanical Components
50051B
1
1
100
C
50053B
5
22
100
C
50053C
2
4
50055
1
12
40
50063B
1
55
100
C
50071
1
16
100
C
50073
1
70
100
50073B
2
201
100
C
50073C
8
31
50074B
1
100
C
-
50075
1
56
100
C
50090B
4
42
100
C
50095
1
38
75
50100
2
6
100
C
C.
Electrical and Instrumentation Construction Procedures
1.
Electrical
51051
1
100
C
-
51051B
1
35
100
C
51053B
2
31
100
P
51054B
1
15
100
C
51055
1
56
100
C
51061
1
20
100
C
510638
2
47
100
P
51064B
4
105
100
C
51065
1
104
100
C
d
2.
Instrumentation
52051
2
22
100
C
52053
2
94
80
52055
1
8
50
52063B
1
62
100
C
III-2
.
.
.
O.
Containment Penetration Procedures
Procedure
Number of
Total Staff
Percent
Reported
Number
Inspections
Hcurs
Completion
Status
53051B
1
8
100
0
53053B
3
13
100
C
53053C
1
4
53055B
1
4
100
C
E.
Welding and NDE Proceduces
Procedure
Number of
Total Staff
Percent
Reported
Number
Inspections
Hours
Completion
Status
55051B
2
4
100
C
55053B
3
10
100
C
55053C
3
19
100
C
550558
1
6
100
C
.
55061B
1
1
100
C
55063B
1
1
100
C
55063C
1
3
100
C
55064B
1
1
100
C
55065B
1
5
100
C
55066B
1
5
100
C
55073C
1
6
100
C
55075B
1
3
100
C
55081B
1
8
100
C
55083B
1
2
100
C
55083C
3
14
100
C
550858
1
2
100
C
55093B
1
14
100
C
l
55151B
2
3
100
C
55152B
2
3
100
C
55153B
5
27
100
C
<
55154B
2
1
100
C
55155B
4
13
100
C
'
55156B
1
3
100
C
55157B
3
8
100
C
55158B
1
2
100
C
55171B
1
100
C
-
'
55172B
1
4
100
C
55173B
3
8
100
C
55175B
1
12
100
C
551768
1
8
100
C
551778
3
7
100
C
55178B
1
100
C
-
55181B
1
4
100
C
55182B
3
6
100
C
55183B
6
8
100
C
55185B
3
24
100
C
551868
2
5
100
C
'
551878
3
4
100
C
55188B
2
9
100
C
III-3
>
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_ _ _ _ . . _ _ _ . _
_
. _ . .
, _ _ _ _
.
.
.
F.
Inservice /Preservice Inspection Procedures
'
Procedure
Number of
Total Staff
Percent
Reported
Number
Inspections
Hours
Completion
Status
73051B
1
9
100
C
,
730528
1
12
100
C
!
73053B
1
5
40
73055B
1
12
40
'
G.
Followup Procedures
3
t
Procedure
Number of
Total Staff
Percent
Reported
Number
Inspections
Hours
Completion
Status
92061B
3
27
!
92700
4
77
'
92700B
22
183
92700C
2
2
'
,
92701B
19
139
,
92702
2
15
92702B
5
24
92702C
1
1
92703
3
8
927038
7
23
92703C
1
1
i'
92704B
1
30
92705B
6
125
!
.
92705C
1
6
'
H.
Independent Inspection Procedures
!
Procedure
Number of
Total Staff
Percent
Reported
Number
Inspections
Hours
Completion
Status
l
,
92706
2
114
92706B
56
562
92706C
23
135
-
,
i
'
l
III-4
.
1
___,_ _ _
_
_
. _ _ _ _ , _ . . . .
, . _ _ . . .
_ - - ._...
. - . .
.
.
.
.
I.
Miscellaneous Procedures
.
Procedure
Number of
Total Staff
Percent
Reported
Number
Inspections
Hours
Completion
._ Status
1.
Meetings, QA, and Design and As-Built
25A11P
2
6
100
C
25C11P
1
7
25124B
3
12
30051B
1
100
C
-
30702B
5
23
30703B
61
22
30703C
22
23
35020B
2
13
100
C
35060
3
19
100
C
35060B
1
5
-
-
35061
1
30
103
C
35061B
1
25
-
-
35065B
3
28
100
C
35100B
1
2
100
C
35200B
1
22
100
C
37051
1
25
20
37051B
2
190
100
C
37055B
3
55
100
C
,
I
III-5
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